On 18th July, Campbells in the Cayman Islands published an article on the consequences of the assessment report which evaluated technical compliance (i.e. having legislation in place) but also, for the first time for the Cayman Islands, evaluated the effectiveness of Cayman Islands legislation.  It says that the report identified gaps in the legislative framework regarding: availability and accuracy of information; interagency co-ordination and cooperation; international cooperation; and monitoring and enforcement, and provided recommendations on how the regime could be strengthened.  As a consequence, a number of legislative changes are proposed and the article lists 13 Bills to be debated in the Islands’ legislature.  It identifies 8 of these as being noteworthy and provides a thumbnail sketch of their proposed changes.  FATF will review the progress made by the Cayman Islands at its June 2020 Plenary to determine if the recommended actions have been taken.  However, it says that the government has stressed that the changes do not move the Cayman Islands closer to implementing public registers of beneficial owners and should not be seen as such – making the list of directors for a company publicly available is a response to a CFATF recommended action.

The CFATF report is available at –


This blog is primarily for my own use, to keep informed and up to date.  However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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